Rice v. Sioux City Memorial Park Cemetery, Inc.

Background

A woman sued a private cemetery in Iowa for refusing to bury her husband, a Winnebago Indian, claiming the cemetery’s contract limited burial privileges to the "Caucasian race." She sought damages for mental suffering and argued the clause violated Iowa law and the Fourteenth Amendment; the trial court and the Iowa Supreme Court addressed the contract clause and rejected reliance on the United Nations Charter.

Reasoning

The central question was whether Iowa courts’ treatment of the restrictive burial clause amounted to state action and thus implicated the Fourteenth Amendment. The case was argued here and the Court initially split evenly on the merits. On rehearing, the Justices focused on an Iowa statute enacted after the litigation began that bans race-based denial of interment, declares such contract clauses null and void, imposes penalties, and permits civil damages under state law. The majority concluded that this new statute and settled state practice removed the case’s public importance and made Supreme Court review inappropriate under the Court’s discretionary review standards, so it vacated the earlier affirmance and dismissed the writ of certiorari as improvidently granted.

Real world impact

Because the Court declined to decide the constitutional question, there is no national ruling about whether enforcing such cemetery clauses violates the Fourteenth Amendment. Similar disputes in Iowa will be governed by the new state statute, including its penalties and civil remedies. This dismissal is not a final decision on the constitutional merits and could be revisited in a different case or posture.

Dissents or concurrances

A dissenting Justice argued that dismissing the case after full argument was improper because serious equal-protection questions remain and the statute still leaves the petitioner uniquely unable to vindicate her rights; the dissent would not have dismissed the case.